Anti-Corruption & Bribery Policy
About this policy
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.
This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.
Who must comply with this policy?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
What is bribery?
Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your line manager or a Director.
Specifically, you must not:
- give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
- accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; and
- give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
You must consider the following issues in all transactions, dealings with officials, and other business matters concerning third parties:
- Territorial risks, particularly the prevalence of bribery and corruption in a particular country;
- Cross-border payments;
- Requests for cash payment, payment through intermediaries or other unusual methods of payment;
- Activities requiring the Company and / or any associated party to obtain permits or other forms of official authorisation;
- Transactions involving the import or export of goods
Gifts and hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the Company’s name, not your name.
If you are given a gift from an existing or potential client, customer or supplier to the organisation you must inform your line manager. If the gift has been given as a gesture of goodwill and appreciation, and is not of substantial value you may be permitted, at your line manager’s discretion to keep the gift or to share it with colleagues. However, if your line manager feels the gift may constitute a bribe you may be asked to return the gift to the sender advising them of the Company’s policy relating to bribery and request that this is respected.
Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
Donations
The Company may make charitable donations. Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity.
All charitable donations must be agreed by the Group Managing Partner first.
Proof of receipt of all charitable donations must be obtained from the recipient organisation.
Under no circumstances may charitable donations be made in cash.
No charitable donation may be made at the request of any party where that donation may result in improper conduct.
The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.
Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.
Record-keeping
You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
How to raise a concern
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must report it in accordance with our Whistleblowing Policy as soon as possible.